ML18361A671
| ML18361A671 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/08/2019 |
| From: | Martha Barillas Plant Licensing Branch II |
| To: | Hamilton T Duke Energy Progress |
| Barillas M DORL/LPL2-2 301-415-2760 | |
| References | |
| EPID L-2018-LLA-0034 | |
| Download: ML18361A671 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 8, 2019 LICENSEE:
Duke Energy Progress, LLC FACILITY:
Shearon Harris Nuclear Power Plant, Unit 1
SUBJECT:
SUMMARY
OF DECEMBER 13, 2018, MEETING WITH DUKE ENERGY PROGRESS, LLC TO DISCUSS LICENSE AMENDMENT REQUEST FOR SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, REGARDING 10 CFR 50.69, "RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS" (EPID L-2018-LLA-0034)
On December 13, 2018, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Duke Energy Progress, LLC (Duke Energy), over a teleconference at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss Duke Energy's license amendment request (LAR) for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris) to adopt Title 10 of the Code of Federal Regulations ( 10 CFR) Part 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors (Agencywide Documents Access and Management System (ADAMS) under Accession No. ML18033B768)." The meeting notice and agenda, dated December 3, 2018, are available in ADAMS under Accession No. ML18337A248. A list of attendees is enclosed.
During the meeting, the NRC staff requested clarification on Duke Energy's Request for Additional Information (RAI) 05.b response provided in their letter dated October 18, 2018 (ADAMS Accession No. ML18291A606). The RAI is a result of the NRC staff's review of Duke Energy's 10 CFR 50.69 LAR, Attachment 6, "Disposition of Key Assumptions/Sources of Uncertainty." This RAI discusses the process for identifying, assessing, and dispositioning assumptions and uncertainties using the guidance provided in NUREG-1855, Revision 1, "Guidance on the Treatment of Uncertainties Associated with PRAs [Probabilistic Risk Assessments] in Risk-Informed Decisionmaking," March 2017 (ADAMS Accession No. ML17062A466). Duke Energy provided its explanation on how it is using the guidance provided in NUREG-1855, Revision 1, and Nuclear Energy Institute (NEI) document NEI 00-04, "10 CFR 50.69 SSC [Structure, System, and Component] Categorization Guideline (ADAMS Accession No. ML052910035)" in this LAR to address uncertainties and assumptions in the PRA models, consistent with what is stated in its RAI 05.b response.
The staff requested clarification on disposition assessments for the table provided in the RAI 05.b response (pages 18 - 37) titled "Uncertainties and Assumptions Not Addressed by 10 CFR 50.69 Factor of 3 Sensitivity/Performance Monitoring." Specifically, how non-safety related SSCs are treated and how the factor of 3 sensitivity is being applied per the guidance in NUREG-1855, Revision 1, since Duke Energy's RAI response appears to be a different and NUREG-1855, Revision 1, since Duke Energy's RAI response appears to be a different and new way in applying NUREG-1855, Revision 1, guidance in its application to 1 O CFR 50.69.
Duke Energy's RAI response and discussions during tt:ie meeting noted that, per section 8.1 of NEI 00-04, a sensitivity is performed following categorization that assumes the unreliability of all low safety significant (LSS) components is increased by a factor of 3 to 5. The results of this sensitivity study then must be shown to demonstrate that even assuming this factor increase, the quantitative guidelines of Regulatory Guide 1.17 4 are not exceeded. Section 8.5 of NUREG-1855, Revision 1 also states that performance monitoring can be used to demonstrate that, "following a change to the design of the plant or operational practices, there has been no degradation in specified aspects of plant performance that are expected to be affected by the change." Therefore, Duke Energy concluded that the LSS sensitivity, combined with the performance monitoring, demonstrates that the potential impact of all uncertainties/assumptions is acceptable.
The NRC staff stated that an interpretation of the discussion in Section 8.5 of NUREG-1855, Revision 1 is that increasing the unreliability of all LSS components by a factor ( of 3 to 5 per NEI 00-04) only addresses the single uncertainty/assumption that there is no consensus approach to model the cause-effect relationship between reliability and reduced special treatment requirements. If only this single source of uncertainty/assumption is addressed by increasing the unreliability of all LSS components, then other sources of uncertainty/assumption need to be addressed without relying on the risk sensitivity study.
There was some discussion on the text in Section 8.5 of NUREG-1855 and the assessments of several assumptions or sources of uncertainty that were provided in Duke Energy's RAI 05.b response. The meeting concluded with Duke and the NRC staff gaining a better understanding of the different interpretations of NUREG-1855, Revision 1.
No regulatory decisions or commitments were made at the meeting. Eight members of the public were in attendance and no comments were provided.
Please direct any inquiries to me at 301-415-2760 or Martha.Barillas@nrc.gov.
Docket No. 50-400
Enclosure:
List of Attendees cc: Listserv
~:llas, Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation
LIST OF ATTENDEES DECEMBER 13, 2018, PUBLIC MEETING WITH DUKE ENERGY PROGRESS, LLC SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 10 CFR 50.69, "RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS,"
LICENSE AMENDMENT REQUEST U.S. Nuclear Regulatory Commission Martha Barillas Brandon Hartle Michael Levine Stephen Dinsmore Jeff Circle Candace de Messieres Dennis Galvin*
Mihaela Biro*
Duke Energy Progress, LLC Arthur Zaremba*
Jordan Vaughn*
Heather Szews*
Steve Kimbrough*
Jennifer Varnedoe*
Members of the Public Allen Moldenhauer*
Jerry Doughty*
Sara Scott*
Rob Burg*
Pamela Burns*
Adam Stein*
Jill Soniker*
Salma Mahzooni*
- Participated by phone Enclosure
SUBJECT:
SUMMARY
OF DECEMBER 13, 2018, MEETING WITH DUKE ENERGY PROGRESS, LLC TO DISCUSS LICENSE AMENDMENT REQUEST FOR SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, REGARDING 10 CFR 50.69, "RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS" (EPID L-2018-LLA-0034) DATED JANUARY 8, 2019 DISTRIBUTION:
Public PM File Copy RidsACRS_MailCTR Resource RidsNrrDorl Resource RidsNrrDorlLp12-2 Resource RidsNrrPMShearonHarris Resource RidsNrrLABClayton Resource
- RidsRgn2MailCenter Resource RidsNrrDraApla JJohnston, NRR BHartle, NRR SDinsmore, NRR JCircle, NRR MLevin, NRR LBurkhart, EDO JBowen, EDO DGalvin, NRR CdeMessieres, NRR MBiro, NRR ADAMS A ccess1on N ML18361A671 o.:
OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NAME MBarillas BClayton DATE 12/27/18 12/28/18 OFFICE NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME UShoop MBarillas DATE 1/7/19 1/8/19 OFFICIAL RECORD COPY
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,y -ma, NSIR/DRA/APLA/BC (A)*
SDinsmore 12/28/18